This is what I sent to Mr. X.  You'll see my comments below each Requests to Admit explaining what each one was aimed to accomplish.

Divorce Paper 17 – Motion to Extend the Protective Order
Judgement for the Dissolution of Marriage

IN THE CIRCUIT COURT OF XXXXXXXXDEPARTMENT – DOMESTIC RELATIONS DIVISION

REQUESTS FOR THE ADMISSION OF FACTS AND THE GENUINENESS OF DOCUMENTS

WARNING: If you fail to serve the response required by Rule 216 within 28 days after you are served with this document, all the facts set forth in the requests will be deemed true and all the documents described in the requests will be deemed genuine.

NOW COMES the Respondent, XXXXXXXX, by and through her attorney, and pursuant to Supreme Court Rule 216, presents the following Requests for the Admission of Facts and the Genuineness of Documents, and Petitioner, XXXXXXXX, is requested to admit in writing the truth of the following specific facts and the genuineness of the following specific documents, copies of which are attached to this Request to Admit.

Petitioner previously owned or operated a business known as Mr. ​Ex Gear.           

1. Mr. ​Ex Gear provided equipment rental. 

This was to establish Mr.​ Ex's previous business that was identical to ABC Gear.  It was very suspicious that he would just stop running his rental business, which was associated with his crew job and therefore SUPER EASY MONEY.

2. While operating XXXXXXXX, Petitioner provided recording labor. 

Again, his equipment rental business was a no-brainer way to double his money.  He was working the jobs, so why not also rent the equipment for the job and double his income??  He had no justifiable reason as to why he closed his business down and suddenly starte​d renting equipment from G'friend, giving her the $60-80k/year income. 

3. True and accurate copies of the purchase orders from XX Films Group are attached hereto as Exhibit "A".  

Every purchase order had Mr. ​Ex listed as the contact of ABC Gear, even after we were hot and heavy into litigation.  Why was this?  I'm not sure we cared for an answer to this question.  We only really cared that the Judge knew that Mr. ​Ex had this exact business before and now was in the exact same position again with this new company (which was STILL HIS).   

4. Petitioner has not directly contributed to education expenses incurred on behalf of the minor child since at least January 1, 2013.

One of the counts of our Petition for Child Support Modification was for Mr. ​Ex to pay 50% of education costs.

5. Petitioner has not directly contributed to the extracurricular expenses incurred on behalf of the minor child since at least January 1, 2013.  

Same rationale as above.

6. Petitioner has not directly contributed to out of pocket medical expenses incurred on behalf of the minor child since at least January 1, 2013.  

Same rationale as above.

7. A true and accurate copy of the call sheet for "XXXXXXXXXXXXXX", job number 1402 worked on February 6, 2014, is attached hereto as Exhibit "B".

This call sheet that he was being asked to admit to was the very call sheet that he himself had submitted as a response to the interrogatory about this job.  Why did we ask this then?  Because he would either admit it and push himself so far back against the wall that he and the wall would become one OR he would lie, which he ended up doing.  He denied this call sheet;  we now had even more written proof that he was not credible.               

8. Petitioner received income from Unnamed Productions in 2013.  

This was to establish the connection between the jobs he worked and the jobs that used ABC Gear.  It was established that ABC Gear did not work ANY JOBS that Mr. ​Ex did not work.

9. A true and accurate copy of the W-2 wage and tax statement from 2013 for revenue from Unnamed Productions is attached hereto as Exhibit "C".  

Same rationale as above.

10. A true and accurate copy of the call sheet for job # 130012 associated with Unnamed Productions is attached hereto as Exhibit "D".  

Same rationale as above.

11. Petitioner performed film crew series for job # 130012 associated with Unnamed  Productions on or about October 4, 2013.  

Same rationale as above.

12. True and accurate copies of business records between Petitioner and Anonymous Productions during 2013 are attached hereto as Exhibit "E". 

Same rationale as above.

13. True and accurate copies of business records between Petitioner and Anonymous Productions during 2014 are attached hereto as Exhibit "F".  

Same rationale as above.        

14.       Petitioner's email address is or was "XXXXXXXX@XXXXXXXX.com".  

All the call sheets had a phone number and email address listed for each crew person and vendor.  Mr. ​Ex's phone number and email were listed as the contact information for ABC Gear, that is up until litigation heated up.  

15. True and accurate copies of business records between Petitioner and Another Production Company are attached hereto as Exhibit "G".  

Again, showing the link between ABC Gear jobs and Mr. ​Ex jobs.

16. True and accurate copies of text messages between Petitioner and Respondent are attached hereto as Exhibit "H". 

Mr. ​Ex and I had exchanged texts about the first court date(s) back in 2013.  Once the $3,202/month child support amount was entered, he signed off on the Motion to Vacate, stating that he was never notified of any court dates.  The texts proved otherwise.

17. True and accurate copies of text messages between Petitioner and Respondent during January and February of 2013 are attached hereto as Exhibit "I".  

Same rationale as above.  This was also used to show that his phone number was his (and not G'friend's) as he had begun to claim.  

18. The minor child born to the parties has severe allergies.  

This was to also force him to lie or admit, given that our Joint Parenting Agreement from years earlier had stated this fact and had been signed by both of us.

If your response to any request for admission is other than an unqualified admission, state for each such request for admission the following:

All facts (not opinions) that you contend support in any manner your refusal to admit or the qualification of your admission.

Mr. X submitted no facts or evidence for any of the above that he denied or objected to.  He merely objected as a matter of opinion, something that Karl exploited in the hearings. 

The identity of all documents, notes, reports, memorandums, recordings, photographs, oral statements, or any other tangible or intangible thing that supports in any manner your refusal to admit or your qualification of your admission. Identification is to be sufficient to identify the aforesaid things in a request for production.

The name and address of the custodian of all tangible or intangible things identified in response to item 2 above.

The name and address of all persons, including consultants, purporting to have any knowledge or factual data on which you base your refusal to admit or the qualification of your admission.

PLEASE TAKE NOTICE that a copy of the admissions, denials, or objections to the foregoing Requests for Admissions, signed and verified by the answering party, should be served upon the undersigned and filed with the Clerk of the Court within 28 days after the service of these Requests for Admissions.

WARNING: If you fail to serve the response required by Rule 216 within 28 days after you are served with this document, all the facts set forth in the requests will be deemed true and all the documents described in the requests will be deemed genuine.

​The purpose of the interrogatory is to have you reveal everything presently known by you that bears on your refusal to admit or your qualification of your admission. The propounding parties at the time of trial will move the court for an order excluding from evidence all tangible or intangible things known to you at the time of your responses to these requests for admissions and interrogatories not disclosed in your responses thereto.